Case Digest (G.R. No. 235110)
Facts:
- Petitioner, Jesus Edangalino y Dionisio, was charged with illegal possession of dangerous drugs.
- Date: September 7, 2011
- Place: District Anti-Illegal Drugs Special Operation Task Group (DAID-SOTG)
- An informant reported that a certain "Amboy" was engaged in illegal drug trade activities.
- A buy-bust operation was conducted, with PO1 Lambino posing as a buyer.
- "Amboy" was apprehended after attempting to flee.
- One plastic sachet of suspected shabu was confiscated from "Amboy" and immediately marked, photographed, and inventoried by PO1 Lambino.
- The seized item was confirmed to be positive for methamphetamine hydrochloride through laboratory examination.
- The petitioner denied the charges and claimed that he had no knowledge of any illegal drug activities and was arrested along with three others.
Issue:
- (Unlock)
Ruling:
- The Supreme Court acquitted the pet...(Unlock)
Ratio:
- The Court emphasized the need for justifiable grounds for non-compliance with mandatory procedures in handling seized drugs during a buy-bust operation.
- The identity and integrity of the seized drugs must be established beyond doubt, considering the unique characteristics of illegal drugs that make them susceptible to tampering or substitution.
- The prosecution failed to comply with the mandatory procedures under Section 21 of the Comprehensive Dangerous Drugs Act, specifically the presence of witnesses from the media, the Department of Justice (DOJ), and an elected public official during the marking, physical inventory, and photographing of the seized item.
- The prosecution did not provide any justifiable ground for non-compliance.
- The presumption of regularity in the performance of official duty could not overcome the presumption of innocence in favor of the accused.
Additional Information:
- The Regional Trial Court (RTC) found the petitioner guilty and sentenced him to imprisonment and a fine, relying on the presumption of regularity in the official function of the police operatives.
- The Court of Appeals (CA) affirmed the RTC's decision, ruling that all the elements for the prosecution of illegal possession of dangerous...continue reading
Case Digest (G.R. No. 235110)
Facts:
The case of Edangalino y Dionisio v. People involves the petitioner, Jesus Edangalino y Dionisio, who was charged with illegal possession of dangerous drugs in violation of Section 11, Article II of Republic Act (R.A.) No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The petitioner was found guilty by the Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the decision. The petitioner filed a petition for review on certiorari before the Supreme Court.
On September 7, 2011, an informant reported to the District Anti-Illegal Drugs Special Operation Task Group (DAID-SOTG) that a certain "Amboy" was engaged in illegal drug trade activities. The DAID-SOTG immediately organized a team to conduct a buy-bust operation against "Amboy." During the operation, the police officers recovered a plastic sachet of suspected shabu from the petitioner. The seized item was marked, photographed, and inventoried by one of the police officers. The seized item was later subjec...